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 Starfighters Aerospace – FAA Petition For Exemption Page 1 

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FEDERAL AVIATION ADMINISTRATION 

PETITION FOR EXEMPTION 

TM 
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FAA PETITION FOR EXEMPTION

Revision 1 10 / 01 / 2010 

By Order Of The Company President 

_________________________________________________________________________________________________

CONFIDENTIAL

_________________________________________________________________________________________________

FAA PETITION FOR EXEMPTION 

MR. RICK SVETKOFF 

PRESIDENT / CHIEF PILOT 

RLB AVIATION, INC. 

1608 N. JASMINE AVENUE 

TARPON SPRINGS 

FLORIDA, 34689-5250 

(727) 452 8817 (Phone) 

Rick.Svetkoff@Starfighters.net 

Mr. McGraw, 

As President and Chief Pilot of RLB Aviation (DBA Starfighters, Inc.), I am formally Petitioning for Exemption from Title 14 

CFR; FAR 91.319(a). 

http://rgl.faa.gov/REGULATORY_AND_GUIDANCE_LIBRARY/RGFAR.NSF/0/c71e4cb4b0e8d48186256ef4004b96d6

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APPLICABLE AIRCRAFT 

The Petition for Exemption would be for the following aircraft: 

N-NUMBER MFR TYPE DESIGNATION 

N104RB LOCKHEED CF-104D STARFIGHTER 

N104RD LOCKHEED CF-104G STARFIGHTER 

N104RN LOCKHEED CF-104G STARFIGHTER 

N990SF LOCKHEED TF-104G-M STARFIGHTER 

N991SF LOCKHEED TF-104G-M STARFIGHTER 

N992SF LOCKHEED TF-104G-M STARFIGHTER 

N993SF LOCKHEED F-104S ASA-M STARFIGHTER 

N994SF LOCKHEED F-104S ASA-M STARFIGHTER 
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REASONING 

I am seeking relief from the regulation in its entirety to enable me to develop my business and continue to advance 

commercial space industry within the United States.

We have carried payloads and persons aboard my F-104 Starfighters as a “public use aircraft” which we highly successful 

with many safety mechanisms and oversight developed by my organization and personnel in conjunction with the United 

States Air Force (USAF) and the National Aeronautics and Space Administration (NASA). These flights helped advance 

technology development for both NASA (cameras, optics and sensors, one of which is currently aboard the International 

Space Station) and Federal Aviation Administration (commercial space airspace proving “Pathfinder”) projects. I have 

been engaged by universities such as Embry Riddle Aeronautical University, Florida State University, Florida Institute of 

Technology and commercial businesses such as Boeing, Lockheed Martin, Northrop Grumman, XCor Aerospace, Virgin 

Galactic, Pratt & Whitney and L-3 who are aware of our success of these flights and wish to conduct similar flights. 

Due to our professionalism, safety record and aircraft capability NASA added us to their highly coveted “Flight Test 

Aircraft Catalog” in 2009. http://airbornescience.nasa.gov/platforms/bpa/starfighters.html

The F-104 is such a capable, proven and recently, highly requested test platform our fleet will be expanding from four to 

nine aircraft. DARPA, Edwards Air Force Base Flight Test Center, the United States Air Force Research Laboratory, 

Untied States Air Force and Navy Test Pilot Schools, and NASA Ames Research Center have all inquired into using my 

organization for various projects. We would like the same opportunities be available to education institutions and 

commercial industry partners to keep America at the forefront of aerospace technology now and in the future. 

As the Space Shuttle program draws to a close KSC will lose critical personnel. As the only private aviation organization 

ever permitted to permanently re-locate and operate from the historic Shuttle Landing Facility, allowing me to “carry 

persons or property for compensation or hire,” I can not only ensure that these personnel remain at work but vastly 

increase my workforce in a climate where almost 13,000 people face unemployment. 

I would like to stress that our request is for aircraft that are in the same type and category discussed in 

FAA-2001-11089-0073.1 (Exemption Docket 6540K) Issued to Mr. Robert F. Collings Jr. and The Collings Foundation 

(See Attachment 3). 
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SAFETY 

Safety is paramount to my organization, aircraft and personnel based at the NASA Shuttle Landing Facility (SLF) on the 

John F. Kennedy Space Center (KSC) in Cape Canaveral, Florida. Our operations at this Federal Government installation 

are subject to oversight not only by the Federal Aviation Administration but are inclusive of the National Aeronautics and 

Space Administration and United States Air Force. Annual safety reviews of our flight operations, aircraft maintenance, 

administration, training, quality assurance and regulation compliance are conducted by both agencies in addition to our 

own internal safety audits, which I feel make us one of the safest and most regulated Part 91 flight operations in the 

country. My professional, full time personnel attend all NASA aviation safety working groups, training and planned 

exercises at KSC. By holding ourselves to a higher standard it is my belief that our location and working airspace (See 

Attachment 8 - Appendix) mitigates a vast majority of risk to the uniformed. 

We have operated without incident since 1996, amassing over 1,000 sorties at over 120 locations across North America in 

support of commercial industry, United States Department of Defense and Federal Government contract work. 

We depart a field located within restricted airspace spanning from the surface to “unlimited” void of commercial and 

general aviation aircraft before transitioning over the Atlantic Ocean to our own ATCAA (Air Traffic Control Assigned 

Airspace) located within warning area W-497A. All flights are with the coordination and approval of Miami Center Military 

Airspace Chief, NASA Flight Operations and the United States Air Force Cape Canaveral Airspace Manager, in addition 

to having my own flight operations personnel in the SLF Control Tower during all flights. 

For these above reasons I sincerely believe granting this exemption would not adversely affect safety. If granted an 

exemption all these safety mechanisms would remain in place and continue to be overseen by both NASA and the USAF. 

The NASA KSC Chief of Flight Operations recently wrote a letter (See Attachment 1) to our governing Flight Standards 

District Office attesting to the professionalism and safety culture in place at my organization. 
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FEDERAL REGISTER SUMMARY 

RLB Aviation, Inc. (DBA Starfighters, Inc.) of Tarpon Springs, Florida is petitioning for exemption from Title 14 CFR; FAR 

91.319(a) to operate its NASA Kennedy Space Center fleet of Lockheed F-104 Starfighter aircraft registered as; N104RB, 

N104RD, N104RN, N990SF, N991SF, N992SF, N993SF, N994SF, to fly “persons or property for compensation or hire”. 
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I thank you for your time to review my petition and look forward to your response. 

Sincerely 

Rick Svetkoff 

President / Chief Pilot 

Starfighters, Inc.